The only ground for appeal is that complying with the notice would be unreasonably burdensome. It would be unreasonably burdensome if the requirement were not reasonable and proportionate for the purpose of checking the person’s tax position, taking into account the value of the information in that context.
There is no right to appeal against a notice requiring:-
- A parent undertaking to provide information or produce documents that form part of the statutory records of the parent or any of its subsidiaries to check the tax position of one or more subsidiaries.
- A partner to provide information or produce documents to check the tax position of one or more of the other partners, in their capacity as such.
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